This Privacy Policy explains how Base Enterprise Joint Stock Company (CÔNG TY CỔ PHẦN BASE ENTERPRISE, "Base Enterprise", "we", "us", "our") collects, uses, stores, shares, and protects information when you use the Amber Note mobile application and any related services (collectively, the "Service"). Amber Note helps you record audio (directly or via a connected Bluetooth recording device), transcribe it to text, generate AI summaries, mind maps, and chat with your notes.
Please read this Policy carefully. By downloading, installing, or using Amber Note, you acknowledge that you have read and understood this Policy. If you do not agree with any part of it, please do not use the Service.
This Policy applies to all users of Amber Note worldwide and describes our practices with respect to personal data as defined under applicable law, including the EU/UK General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), and other applicable data protection laws. Terms such as "personal data," "processing," "controller," and "processor" have the meanings given to them under GDPR, and are used interchangeably with "personal information" under CCPA where relevant.
This Policy does not apply to any third-party websites, products, or services that may be linked to or accessible from within the Service, including the third-party AI providers described in Section 3, each of which maintains its own privacy policy.
| Data | When it's collected | Required? |
|---|---|---|
| Display name / nickname, avatar | When you set up your profile | Optional |
| Email address or social sign-in identifier (Google / Apple ID token) | If you choose to sign in with a third-party account | Optional |
| Note titles | When you create or edit a note | Optional (auto-generated if left blank) |
| Support requests | When you contact us for help, including any text, screenshots, or attachments you choose to send | Optional |
The core function of Amber Note is recording and transcribing audio. This category of data may contain your voice, the voices of other people you record, and the substance of your conversations — which may include sensitive personal data about you or third parties (for example, health, financial, or other confidential information discussed in a recording). You are responsible for obtaining any consent required from other people before recording them.
| Permission | Purpose | Can you decline? |
|---|---|---|
| Microphone | Record audio, including in the background while you use other apps | Yes — recording will not function without it |
| Bluetooth | Discover and connect to a compatible external recording device | Yes — only needed for Bluetooth recording |
| Location (When In Use) | Used only to help discover nearby Bluetooth recording devices; we do not use this to track your movements or attach location metadata to your notes | Yes |
| Photo Library | Attach or save images, such as a profile avatar | Yes |
| Notifications | Alert you when a recording or transcription finishes processing | Yes |
You can grant or revoke any of these permissions at any time from your device's Settings app. Revoking a permission may disable the corresponding feature.
We design this category of data collection to support and improve the Service, not to build an advertising profile about you, and we do not combine it with the content of your recordings.
If you choose to sign in using a third-party account (for example, Google or Apple), that provider will share limited profile information with us — typically your name, email address, and a unique account identifier — so that we can create and secure your Amber Note account. We do not receive your third-party account password.
To provide transcription, summarization, and related AI features, Amber Note sends the audio and/or text data described in Section 2.2 to the following third-party AI providers. We only send what is necessary for these providers to perform the requested function, and we ask for your explicit consent in-app before any such data is transmitted (see Section 9).
Used for: audio transcription, speaker diarization, note summarization, mind map generation, and conversational AI ("chat with your notes").
Data sent: the audio file, the resulting transcript text, and the note title.
Provider's privacy policy: policies.google.com/privacy
Used for: audio transcription, used as a fallback when the primary transcription provider is unavailable or fails.
Data sent: the audio file.
Provider's privacy policy: openai.com/policies/privacy-policy
These providers process your data as independent data processors/controllers under their own terms strictly to return a transcription or AI-generated result to Amber Note. We do not permit these providers to use your recordings or transcripts to train their models on our behalf, to the extent such controls are offered by the provider's API terms. We do not send your device identifiers, precise location, contacts, photos, or account credentials to these providers.
We may add, remove, or change AI providers as the Service evolves. Material changes to who processes your data will be reflected in an updated version of this Policy and, where required by law, we will ask for your renewed consent.
| Purpose | Details |
|---|---|
| Provide the Service | Record, store, transcribe, summarize, and organize your notes; sync your data across your signed-in devices, if applicable. |
| Improve & secure the Service | Diagnose crashes, monitor performance, detect abuse or unauthorized access, and prevent fraud. |
| Customer support | Respond to your questions, troubleshoot issues, and communicate about your account. |
| Legal compliance | Comply with applicable law, respond to lawful requests from public authorities, and enforce our User Agreement. |
We do not use the content of your recordings or transcripts for advertising, and we do not sell your personal information (see Section 11). Amber Note is free to use, and we do not currently collect any billing or payment information.
Where GDPR applies, we rely on the following legal bases to process your personal data:
We do not make any decision that produces legal effects concerning you, or similarly significantly affects you, based solely on automated processing without human involvement.
Your recordings, transcripts, and account data are stored on secure cloud infrastructure operated by our hosting providers. Because our AI providers operate global infrastructure, your audio and transcript data may be transferred to, and processed in, countries other than your own, including the United States.
Where we transfer personal data internationally, we rely on one or more of the following safeguards:
We implement industry-standard technical and organizational measures designed to protect your information, including encryption of data in transit, access controls limiting who can view your data internally, and regular review of our security practices. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
| Data category | Retention period |
|---|---|
| Account data (name, email, sign-in identifier) | Until you delete your account, plus a limited period afterward as required to comply with legal or security obligations |
| Audio recordings & transcripts | Until you delete the note, or until you delete your account, whichever is earlier |
| Diagnostic / crash / log data | Up to 12 months |
| Support communications | Up to 12 months after the request is resolved |
When retention is no longer necessary, we delete or irreversibly anonymize your data, except where a longer period is required or permitted by law (for example, to resolve disputes, enforce our agreements, or comply with a legal obligation).
We do not sell your personal information, and we do not share it with third parties for their own advertising or marketing purposes. We disclose information only in the following circumstances:
Before any audio or note content is sent to a third-party AI provider for the first time, Amber Note presents an in-app consent screen explaining what data is sent and to whom. If you decline, AI-powered features (transcription, summary, mind map, chat) will be unavailable, but you may still record and store audio locally on your device where technically possible.
You can review or withdraw this consent at any time from Settings → Privacy within the app. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, and will disable AI features going forward.
Subject to applicable law, you may have the right to:
You can exercise most of these rights directly in the app under Settings → Account (edit profile, delete a note, or delete your account). For any request we cannot fulfill in-app, contact us using the details in Section 16. We may need to verify your identity before completing a request, and we will respond within the time required by applicable law (generally within one month, extendable by up to two additional months for complex requests, with notice to you).
We do not sell or "share" (as defined under CCPA/CPRA) your personal information for cross-context behavioral advertising. Because we do not use tracking technologies for cross-site/cross-app advertising, there is no sale or share of personal information to opt out of. If this changes, we will update this Policy and provide the required opt-out mechanism.
Amber Note is not directed to children under the age of 13 (or the minimum age required by your country's law, whichever is higher), and we do not knowingly collect personal data from children under that age without verifiable parental consent. If we learn that we have inadvertently collected personal data from a child without appropriate consent, we will delete it promptly. Parents or legal guardians who believe their child has provided us with personal data may contact us using the details in Section 16 to request access to, or deletion of, that data.
To reliably continue recording, sync data, and deliver notifications when the app is minimized, Amber Note may need to run certain processes in the background (for example, keeping a Bluetooth connection to a recording device active, or completing an in-progress audio upload). This background activity is limited to functions necessary to complete an action you initiated, and can be limited by adjusting background app permissions in your device Settings — though doing so may interrupt an active recording or Bluetooth connection.
If you access Amber Note from outside Vietnam, you understand that your information will be transferred to, stored, and processed in Vietnam and potentially in other countries where our service providers and AI partners operate, as described in Section 6.
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. We will post the updated Policy in the app and/or on our website and revise the "Last updated" date above. For material changes — particularly any change to the third-party AI providers we use or the categories of data shared with them — we will provide additional notice in-app and, where required by law, obtain your renewed consent before the change takes effect. Your continued use of the Service after a change becomes effective constitutes your acceptance of the revised Policy.
If you have questions, concerns, or requests regarding this Privacy Policy or how your data is handled, please contact us at:
Base Enterprise Joint Stock Company (CÔNG TY CỔ PHẦN BASE ENTERPRISE)
Address: Tầng 3, Tòa A (No.2) GoldSeason, 47 Nguyễn Tuân, Phường Thanh Xuân Trung, Quận Thanh Xuân,
Hà Nội, Việt Nam
Email: contact@base.vn
If you are located in the European Economic Area or UK and are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.